Updated on 02/01/2020
The data controller is LABORATOIRES FILL-MED, whose registered office is at 2 rue de Lisbonne – 75008 Paris, France registered on the Paris Trade and Companies Register under no. 811 667 963, with share capital of €2,808,390 (“FILL-MED”).
The processing of personal data is governed by:
- French Law no. 78-17 of 6 January 1978 on data protection, as amended on 1 June 2019 (the “French Data Protection Law”);
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, which entered into force on 25 May 2018 (the “GDPR”).
1. Type of data collected
FILL-MED ensures that it only collects Data that is strictly necessary in relation to the purpose for which it is processed.
* When you register for our Newsletter, we collect:
• Your email address.
2. Purpose of collection and legal basis
FILL- MED processes data for a clear, legitimate and specific purpose.
More specifically, the Personal Data is collected in order to:
- manage subscriptions to the newsletter and to the various electronic communications sent by FILL-MED;
- manage the benefits associated with the newsletter subscription.
The legal basis for the processing is your consent thereto, our legitimate interests and the performance of contractual obligations.
3. Recipients of Data
The Data is collected for the exclusive use of FILL-MED and shall not be transferred to any third party.
It may be sent to any of LABORATOIRES FILL-MED’s subsidiaries in France or outside France (hereinafter collectively referred to as the “FILL-MED Group”) including in connection with:
- the sending of newsletters and electronic communications.
We may also share your Data with our technical service providers (for example, our subcontractors, such as our hosting provider).
Our subcontractors are responsible for processing the Data on our behalf and in accordance with our instructions, solely for the purpose(s) that is/are the subject of the subcontracting arrangement. They are subject to contractual confidentiality and security obligations.
4. Transfer of your Data outside the EU
Your Data will not in principle be transferred outside the EU. However, should this be the case, we shall ensure that:
- the Data shall be transferred to countries recognised as offering an equivalent level of protection, or
- the Data will be transferred to entities with privacy shield certification, or
- where Data is transferred to countries that are not recognised by the CNIL as having a sufficient level of protection, one of the mechanisms provided for under applicable regulations as offering appropriate guarantees shall be used, in particular the adoption of standard contractual clauses.
5. Retention period
The retention periods for your Data depend on the processing purposes for which it is used. FILL-MED will store your Data only for the time necessary to carry out the operations for which it was collected, in compliance with prevailing laws.
If you have registered for the Newsletter, your Data shall be retained for a period of three years after the date on which we last have contact with you.
6. Your rights
Under the regulations on the protection of Personal Data, you have a right of access, query, rectification and erase in respect of your Data, the right to restrict processing and to data portability and the right to object to processing, in particular to such Data being used for direct marketing purposes.
* By exercising your right to query and access your Data, you may obtain confirmation as to whether or not your Personal Data is being processed by FILL-MED, the conditions of such processing (purpose, recipients, sources, etc.) and receive a copy thereof (FILL-MED may charge a reasonable fee for any additional copies);
* The right of rectification allows you to rectify any inaccurate or incomplete Data at any time;
* The right of erasure allows you, subject to the exceptions set out in the regulations (e.g. where data is required to be stored in order to comply with a legal obligation) to ask FILL-MED to erase all or some of your Data, on one of the following grounds:
- the data is no longer necessary in relation to the purposes for which it was collected.
- you wish to withdraw your consent on which the processing of your Data was based (to the extent that there is no other basis for such processing);
- you wish to object to the processing on grounds relating to your particular situation, where the processing is based on the legitimate interests of FILL-MED;
- you consider and can establish that your Data has been unlawfully processed;
- your Data has to be erased pursuant to a legal obligation provided for under the regulations.
* The right to restrict processing may be invoked in the following scenarios:
- where you dispute the accuracy of your Data;
- where the processing is unlawful but you object to the erasure of your Data and instead require processing of your Data to be restricted;
- where FILL-MED no longer requires your Data but it is still required for the establishment, exercise or defence of legal claims;
- where you object to processing that is based on the legitimate interests of FILL-MED, pending verification of whether the legitimate grounds of FILL-MED override your grounds.
* The right to data portability allows you to receive the Data you have provided to us in a structured, commonly used format and to transfer such Data to another data controller. Where technically feasible and permitted by the regulations, you may request that such Data be directly transmitted to another controller by FILL-MED;
* The right to decide how your Personal Data is dealt with after your death allows you to make precise arrangements for your Data after your death, through the adoption of general or specific guidelines. FILL-MED undertakes to comply with these guidelines;
* The right of object allows you to object to processing on grounds relating to your particular situation or to withdraw your consent;
* The right to lodge a complaint with a supervisory authority if you consider that FILL-MED is not compliant with its obligations concerning your Data;
LABORATOIRES FILL-MED, Department responsible for managing personal data, 2-4 rue de Lisbonne, 75008 Paris, France.
FILL-MED undertakes to respond to you as soon as possible and, in any event, within one month of receiving your request. This period may be extended by two months where required as a result of the complexity and the number of requests sent to FILL-MED. You will be informed in advance of any such extension and the reasons for the delay.
FILL-MED ensures that your Data is secure by using appropriate technical and organisational resources. FILL-MED takes care to secure your Data in order to prevent it from being distorted, damaged, destroyed or disclosed to unauthorised third parties.
In the event that we become aware of any unlawful access to your Data associated with the processing for which we are responsible, we undertake to notify you of the incident as soon as possible where legally required to do so.
8. Cookies on the FILL-MED Website
When you first access the Website, you are notified by a band at the bottom of the screen that information on the way in which you use the website may be recorded in files known as cookies.
“Cookies” are small text files saved on the hard disk of your device (computer, tablet, mobile, etc.), of limited size, that allow us to recognise your computer, tablet or mobile with a view to customising the services we offer you and ensuring that the website functions properly.
8.1 General information on cookies on the Website
You may accept or refuse to allow cookies to be installed or read at any time.
Depending on the type of cookie used, your prior consent to the installation and reading of cookies on your terminal may be required.
8.2 Cookies that do not require consent
In accordance with the recommendations of the Commission Nationale de l’Informatique et des Libertés (the French data protection authorities or CNIL), certain cookies do not require your prior consent insofar as they are strictly required for the website to operate or where their sole purpose is to allow or facilitate electronic communications.
On the FILL-MED Website, these cookies are used to:
- compile statistics and information on how often the various elements of the Website are visited and used (sections and content visited, clickstream data, etc.) in order to improve the attractiveness and usability of its services;
- adapt the presentation of the Website to your terminal’s display preferences (language used, display resolution, operating system used, etc.) during your visits to the Website;
- implement security measures, in particular to reconnect to the service after a certain period of time.
These cookies are also governed by this policy to the extent that they are issued and managed by FILL-MED. Under the law, cookies may be stored for a maximum of 13 months.
8.3 Cookies requiring your prior consent
Certain cookies require your consent before being placed or read on your device. This requirement relates to cookies issued by third parties that are categorised as “persistent” insofar as they remain on your device until they are deleted or expire (they continue to be saved on your device after your browser is closed). This group of cookies includes audience measurement cookies (in particular Google Analytics), advertising cookies and social network sharing cookies (in particular from Facebook, Pinterest, Instagram and YouTube).
On the FILL-MED Website, as such cookies are issued by third parties, their use and installation are subject to their own privacy policies, a link to which is provided below.
Social network cookies are issued and managed by the publisher of the relevant social network. Four social networks are linked to from the FILL-MED Website and may potentially place or read cookies on your device, subject to obtaining your consent:
- Facebook, whose policy on cookies you may read by clicking on the following link:
- Pinterest, whose policy on cookies you may read by clicking on the following link:
- Instagram, whose policy on cookies you may read by clicking on the following link:
8.4 You may use a number of cookie setting tools
Most Internet browsers are set by default to allow cookies to be stored. Your browser offers you the ability to change these standard settings so that all cookies are systematically rejected or so that only some cookies are accepted or rejected depending on who has issued them.
If you activate a Do Not Track setting in your browser, no information about you will be collected, thereby preventing your profile from being established, and neither you nor your device will be tracked.
NOTE: We draw your attention to the fact that refusing to allow cookies to be stored on your device may, however, alter your user experience as well as your access to certain services or features of the Website. FILL-MED does not accept any liability for the consequences associated with any deterioration in your browsing conditions that occurs as a result of you choosing to refuse, delete or block the cookies required in order for the website to operate. Such consequences shall not be deemed to constitute a loss and you will not be entitled to claim any compensation as a result.
Your browser also allows you to delete existing cookies on your device and can be configured to notify you when new cookies are placed on your device.
Each Internet browser has its own cookie management settings. Please use the following links to access the relevant menu of your browser and to find out how to change your cookie preferences:
- Chrome: https://support.google.com/chrome/answer/95647?hl=en
- Firefox: https://support.mozilla.org/en-US/products/firefox/protect-your-privacy/cookies
- Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11
- Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/mac
9. Updates to this policy
This policy may be updated at any time, in particular to reflect laws and/or regulations and/or any recommendations issued by the CNIL or the EDPB. We therefore recommend that you consult this page on a regular basis.